How have the courts determined that there was probable cause to arrest and not a false arrest?

Drawing all reasonable inferences in Burgess's favor, we conclude as a matter of law that probable cause existed to arrest him. Two witnesses, Pridgen and Grady, separately identified Burgess as the shooter in a photo array. Burgess does not argue that the photo array was unduly suggestive, but rather that the detectives should have been aware of inconsistencies in the descriptions given by the interviewees. There is no evidence, however, that either officer was aware of the inconsistencies. Moreover, even if they were aware of the inconsistencies, they reasonably relied on the independent positive photo identifications when making the probable cause determination. Finally, Burgess's assertion that the two witnesses conspired with another individual to wrongfully accuse him of murder is pure conjecture and not sufficient to defeat summary judgment. See Goenaga v. March of Dimes Birth Defects Found., 51 F.3d 14, 18 (2d Cir. 1995). Accordingly, we affirm the district court's conclusion that there was probable cause to arrest and thus no false arrest.